Contents

1. Foreword
2. Introduction
3. Enough Compromises
4. Text of Agreement between Canada and The Netherlands
5. Military Flight Training in Nitassinan
6. Evidence of Negative Impacts of Military Aviation on Wildlife
7. The Innu, the Environmental Impact Statement and its Relevance to The Netherlands

• Appendix 1 Table of Contents EIS
• Appendix 2 The course of the EIS Process
• Appendix 3 Mandate of the Environmental Assessment Panel to Department of National Defense
• Appendix 4 Chronology of Military Flight Training Activities over Innu Territory
• Appendix 5 Quotes in the Press of Dutch Military Officers
• Appendix 6 Statements by the Dutch Government During Parliamentary Sessions
• Appendix 7 Letter by the Royal Netherlands Air Force to a Concerned Citizen

Foreword

1993 has been declared Year of Indigenous Peoples by the United Nations. It would be high time. Around the world, the existence of indigenous peoples is being threatened. In 1993, the world community has the chance to save from oblivion those who belong to the most marginalized groups of the world, the indigenous peoples. This an opportunity to create the conditions in which these peoples can fully realize their cultural identity.

Far-reaching measures are required for this. Within the United Nations, a Declaration on the Rights of Indigenous Peoples has been drafted. It is hoped that this Declaration will be adopted by the end of 1993 by the General Assembly of the United Nations. The Declaration, in which self-determination and participation rights will be included, may thereafter serve as an important guideline for action of national governments and for the international community.

In 1993, also The Netherlands has the opportunity to take efforts to improve the plight of indigenous peoples. The Advisory Committee on Human Rights and Foreign Policy and the National Advisory Council on Development Cooperation have suggested a great number of policy measures in such fields as the development cooperation and human rights policies of the Dutch government.

A concrete field on which The Netherlands can directly take steps is the low-level exercises of the Royal Netherlands Air Force above Innu territory in Canada. These exercises form a direct threat to the environment of the Innu. In the symposium that will be held on February 5, 1993, these exercises will be analyzed carefully from the points of view of human rights and the environment. The organizers of the symposium, the Foundation Innu Support Group and the Prof. mr B.V.A. R”ling Dispuut, in this way give a concrete contribution to the United Nations Year of Indigenous Peoples. I wish all participants in the symposium a very fruitful and interesting day. I hope that this symposium will lead to the formulation of concrete recommendations that will be of direct influence on the Dutch policy regarding low-level flying exercises above Innu territory in Canada. "The sky above Innu land in Canada" is after all of direct importance for the quality of life in Innu land itself.

C. Flinterman,
Professor of constitutional and international law
University of Limburg.

Introduction

Innu culture cannot be lived on reserves. Their history is encoded in the land around them. Every lake, river and mountain on the Quebec-Labrador peninsula has a name in the Innu language. After they settled permanently in villages, the Innu became projects for the work of the well-intending, but misguided authorities. The Roman Catholic church, which first introduced them to Christianity, persuaded Innu parents to send their children to church-run schools where Innu history, language, geography and culture were ignored. This assimilation process has created problems that didn't exist in Innu society 40 years ago - such as unemployment, alcoholism, teen suicide, violent crime and fatal accidents related to drinking and drug abuse.

To resolve the crisis, hundreds of Innu have been returning to the bush for half the year, where they hunt and live off the land as before. In the bush, or nutshimit as the Innu call it, their health and peace of mind are restored.

In 1946 a military base was built near Goose Bay. A town sprang up around the base and is now home to 8,000 people. It was not until 1980 that Canada invited NATO countries to participate in low-level bomber training flights from that airfield. Operational training in the average central and northern European NATO air force focuses mainly on low flying scenario based training. Because of restrictions 'at home', the Royal Air Force, the German Luftwaffe and the Royal Netherlands Air Force have all moved to Goose Bay.

At present about 10,000 sorties fly over Innu land using the latest model of supersonic aircraft that zoom low over the trees. The F-16 jets of the Royal Netherlands Air Force produce a noise of 145 decibels. Canada claims to enforce rules that restrict aircraft from flying near Innu hunting camps and sensitive wildlife areas. The Innu say this is a lie and that the rule is ignored. In any case, Innu camps are not fixed. People move within about a one hundred mile radius, following the animals, along riverbanks and lakeshores, and through valleys. This is the way the Innu have lived peacefully and harmoniously for millennia.

The Innu fear, that due to the military exercises, their culture may disappear forever. Bombing ranges are being created in their homeland, and European low-flying jets spread noise, pollution and fear.

The response of the Dutch government may be summarized in three points: - The area where low-level flying is practiced, is hardly inhabited as for most of the time, the Innu remain in their villages outside the training area. - If there are Innu around in 'the interior', their hunting camps and sensitive wildlife areas are avoided by the low-flying jets. - Canada behaves in a respectful and responsible manner towards its indigenous peoples and the Dutch government has no business to mingle into Canada's internal affairs.

The Prof. mr R”ling Dispute and the Foundation Innu Support Group have joined hands to organize a symposium on February 5, 1993, to put these assumptions to the test. Does The Netherlands not have its own responsibility with regards to possible violation of human rights and environmental law? To what extent can the claims of the Dutch government be weighed against the claims of the Innu and wildlife experts as to the contentions surrounding flight training admissibility?

At the symposium a distinction will be made between human rights aspects and environmental aspects.

Human rights

"We cannot help observing that, in past years, when the Commission first took up the question of indigenous rights, The Netherlands was in the forefront. We are particularly disappointed that this government, above all, has taken steps to participate in activities which could lead to our destruction. For indigenous peoples, the loss of our land - its use or exploitation by others without our participation or consent - is the road to ethnocide and even genocide."

"The actual military training constitutes an infringement upon the fundamental rights of individuals through the alterations they cause to their physical and mental well-being. It also constitutes an infringement up on the collective rights of the Innu people by causing their traditional activities, which are intrinsically linked to their existence and to the vitality of their collectivity, to become very difficult to pursue."

"The Netherlands may be confident that the legislation of Canada, also party to this treaty, is in accordance with the norms stipulated by the treaty. Given the permission of the Canadian government, the Dutch government may and must be confident that the exercises can be held without violating Canadian law. The assertion that the Dutch conduct would be in violation of the treaty boils down to the assertion that the Canadian legislation doesn't meet the requirements of the treaty on this point. It is not up to the Dutch government to question the legitimacy of the Canadian permission for low-level flying exercises."

"The Netherlands not only has the obligation to assay a bilateral agreement as this one to fundamental norms of international law, but our country should also check if the agreement could become contradictory to the specific legal interests of vulnerable indigenous peoples."

Environmental law

"Defense and environment. Two notions which, at first glance, have little in common. Low flying jet-fighters and empty cartridge-cases in nature would not appear to reflect sentiments of love for the environment. Our military force, however, has the best intentions for the environment."

"We'll have to be extremely sensitive and alert whenever we, as in this case, transfer nuisance and harmful activities to elsewhere, in order to be spared of it ourselves. The dumping of chemical waste in the Third World, nuclear explosions in the Pacific Ocean, roaring noise above the natural areas of the Innu - Is this not contradictory to the rights of human beings? Apparently not; just as long as it doesn't give trouble to Ottawa, Paris or The Hague."

We are proud to invite you to partake in the symposium, to listen to the contributors and to join in on the discussions. After the symposium, the proceedings will be published and made available to serve as solid new documentation on the legal and moral aspects of this confrontation between hunters and bombers - between the Innu of Nitassinan and the Royal Netherlands Air Force.

The Innu Support Group takes full responsibility for any amendments in the contents or structure of contributions to this reader, made through the process of our translations from Dutch to English. It is our hope that the intent of the authors have been fully represented.

We hereby would like to thank the funding organizations which helped make this symposium possible. To date of publication of this reader, these are: The Foundation for cology and Development in Mill Valley, California; de Congregatie van de Zusters van Liefde in; Stichting Verbiedt de Kruisraketten; De Haella Stichting and Stichting Dialoog. We also wish to express our gratitude to the University of Limburg which provided us with an excellent location for our purpose and other essential facilities. Additional thanks to Kink Videogroep for producing the film 'Hoe kun je de lucht bezitten?' ('How Can One Own The Sky?') which will be premiered at the symposium, and Stichting Ide‰el Organiseren for their indispensable support and advice. Last but not least, we are very thankful for the enthusiastic participation of the speakers on the symposium, the contributors to this reader, and for the invaluable contributions of the many volunteer workers behind the scenes.

Maastricht, Prof. mr. R”ling Dispuut The Hague, Foundation Innu Support Group.Enough Compromises [hier de tekst van Daniel Ashini uit het boek Nitassinan, N.B.: laatste alinea niet opnemen en aan het eind de volgende tekst opnemen:] (excerpted from the book 'Nitassinan. The Innu Struggle to Reclaim Their Homeland' by Marie Wadden. Vancouver: Douglas & McIntyre, 1991) Military Flight Training in Nitassinan by Peter Armitage (Peter Armitage is an anthropologist and independent researcher retained by the Innu Nation to assist in technical matters related to military flight training in Innu airspace in Labrador-Quebec)

Members of First Nations, peace, church and environmental groups celebrated NATO's decision on May 22, 1990, not to build a proposed Tactical Fighter and Weapons Training Centre in eastern Quebec and Labrador. Even the pro-military expansion MP from Labrador, Bill Rompkey, said the decision was good news because the base would have been too much too quickly for the town of Happy Valley-Goose Bay. The Canadian Department of National Defense expressed great disappointment, however, and vowed to expand the existing training by allied air forces through bilateral agreements. DND hoped to achieve 18,000 annual sorties in Quebec-Labrador by 1996, although this level now appears to have been excessively optimistic.

In any event, the Canadian military continues to promote low-level and other types of training at Goose Bay. The bilateral agreements with Germany, The Netherlands, and Great Britain that cover such training expire in 1996, but allied air forces have all expressed interest in renewing their contracts so that training can continue well into the future.

During the 1991 flying season, which lasted from April 1 to November 12, there were 6,656 training flights at low level. In the 1992 flying season, DND anticipated 8,400 flights involving about 60 aircraft. The Dutch currently train with F-16s while the Germans use the Tornado and aging F-4 Phantom. For its part, the RAF conducts its training mostly with Tornado GR1s which were used extensively in the Gulf War against Iraq. The RAF also planned to conduct about 350 flights at higher levels with the Tornado F3 aircraft, which was originally tasked to intercept long-range Soviet bombers.

Since the demise of the proposed NATO Training Centre, DND has continued to promote its avoidance programme as the solution to the potential negative impacts of military aviation noise. Noise sensitive areas such as Innu and Inuit camp sites and concentrations of caribou, ducks and geese, birds of prey, and moose would be avoided by the low-flying jets. The giant military contractor, SNC-Lavalin, and a subcontractor, Renewable Resources Consulting Services Ltd. of Sidney, B.C., have been retained by DND to develop and help implement the avoidance programme.

Labrador and Quebec Innu, who remain highly critical of the flight training, argue that DND's avoidance programme cannot work because there are too many noise sensitive areas to avoid. They note that DND first made its promise to avoid all these areas without having done much research to find out where they were located. But when its consultant started to do some of the research, they found too many good places for ducks and geese and other wildlife.

It is noteworthy that the avoidance restrictions introduced thus far by DND have generated serious concerns among Allied air forces training at CFB Goose Bay. For example, during the Resource Use Advisory Group (RUAG) meetings at CFB Goose Bay on August 21, 1990, Lieutenant Colonel F. Schneider of the German Air Force (GAF) advised that they were denied low level access to the entrance corridor leading to the north training area, which precluded use of the range during certain weather conditions. He felt that one-third of their missions were lost due to the imposition of this restriction (RUAG, Aug.21, 1990:4). At the same meeting, Royal Netherlands Air Force (RNLAF) commander, Lieutenant Colonel Henk Krauss indicated that "he is officially representing an Air Force which is in conflict with what the RUAG is hoping to achieve. He advised that the existence of the RUAG will mean limitations for the RNLAF" (ibid.:4). At the November 15, 1990, meeting of the same group, the Royal Air Force (RAF) Commanding Officer "expressed concern that Allied flying operations are being restricted because of the affect (sic) of overflights on fur bearing animals" (RUAG, Nov.15, 1990:4).

In December 1991, Allied air force commanders reiterated these concerns about the impact of the avoidance programme on their flight training. For example, RAF Wing Commander Erskine told the Happy Valley-Goose Bay newspaper, The Labradorian, that there could come a time when restrictions may outweigh the positive side of training at CFB Goose Bay. "We've got to see how things pan out. Obviously if more and more and more restrictions are placed on us, there comes a point when there is no sense - we can't do what we want to, so there is no sense in being here" (December 9, 1991:2).

The avoidance restrictions that have become such a bone of contention for the Allied air forces are based on the potential for negative impacts on caribou, moose, migratory waterfowl, and raptors. They have been imposed as a result of DND's promises to design and implement mitigative measures to protect people and wildlife from potentially negative impacts from low- level flying. Furthermore, the promises were made in the context of political pressure from the Innu, peace, church and other groups to halt the flight training outright. In any event, in DND's view, "there are unknowns about the impacts that low- level flying may or may not have over wildlife" (letter from Bill McKnight, to Robert R. de Cotret, Dec. 21, 1990), but in the absence of conclusive evidence and cause-effect research to determine the nature of potential impacts, avoidance of sensitive wildlife would prevent such impacts from occurring in the first place.

With this approach to the problem of potential impacts on wildlife, there is a risk that as Allied air forces increasingly have difficulty living with avoidance restrictions, DND and other agents with a stake in the continuation of flight training at CFB Goose Bay will argue that there is no evidence of negative impacts, so why bother with an avoidance programme? For this reason, it is important to reiterate the need for the immediate design and implementation of the kind of cause-effect research that was proposed by the Canadian Wildlife Service (CWS). In a letter to one of the consultants working on the preparation of the Goose Bay EIS, Ian Goudie, a CWS biologist, noted that

"there has been extremely little research (if any) on effects of low-level jet-fighter flights on waterfowl species in the boreal forest [and therefore] there was clearly a need to design within the framework of the environmental assessment, a rigorous experiment applying control versus experimental plots to properly address whether or not there is a measurable impact. I had discussed this at length with yourself and the field workers yet I gather this work was not conducted. It is unclear to me why this experimental work was not applied to the moulting concentrations of Black Duck for which we suspect there was measurable impact (as displacement) on Snegamook Lake delta in the 1980-82 period" (letter from Ian Goudie, CWS, to David Lemon, Fudge and Associates Ltd., Feb. 15, 1988).

For example, the U.S. Fish and Wildlife Service (USFWS) conducted a survey of all its regional directors, research center directors, refuge managers, field officers, and hatchery managers in early 1987 to determine the nature and extent of aircraft-induced impacts on the behaviour and habitat utilization of fish and wildlife populations (Gladwin, et al. 1988). The proximity of many USFWS field installations to military and civilian airports and flight training areas gave USFWS personnel opportunities to observe apparent adverse effects. Waterfowl were by far the most frequently reported animal group disturbed by aircraft. Several installations reported that some species of waterfowl were permanently driven off refuges by frequent flying activity (Gladwin, et al. 1988).

Moving to raptors (birds of prey), Ellis (1981) observed the effects of aircraft disturbance on four peregrine falcon nests that were overflown four, five, six, and ten times, respectively. His study indicated that the falcons were alarmed by loud noise (82-114 dB) when jets flew within 500 m. (1,640 ft.) of the nest site. In some cases, when jets flew within 250- 300 m. (820-984 ft.) of the nest, adults fled, leaving the young to cower alone. Ellis concluded that even short-term exposure could lead to negative reproductive outcomes. Long-term exposure and high levels of exposure are even more likely to affect reproduction negatively. In the case of low-level flying in Labrador, Linegar (1992) noted that in 1987, Harp Lake canyon (in LLTA 1) experienced an estimated 125-250 training flights per month during the flying season. Since Ellis' work shows that as few as four overflights can cause reproductive failure, it is reasonable to assume that falcons nesting in portions of the flight training area that are frequently overflown, such as Harp Lake Canyon, Ugjoktok River valley, and the Kogaluk River valley may experience reproductive failures.

Fleischner and Weisburg (1986) evaluated the effects of jet flights on bald eagle behaviour and population dynamics. During field observations, eagles reacted to 55% of small jet aircraft overflights. Minimum reactions of merely looking at the aircraft and flying from the perch site were observed when the jets were a great distance from the birds.Eagle reactions to jets increased two-fold when the eagle-jet distance was 0.8 km (0.5 mile) or less. The authors indicated that repeated flight from perches and interrupted activities due to aircraft disturbance could have a negative effect on bald eagles if the overflights occurred frequently. As there was no indication that the birds would habituate, the authors advised that the number of jet flights per day should be minimized.

In his own assessment of DND's avoidance programme vis--vis raptors, Linegar (1992) expressed concern that event a single close overflight of a nest could cause an adult Peregrine to flee a nest and dislodge an egg from the scrape. Furthermore, eggs or chicks could be exposed to harsh climatic conditions during an adult's escape response. In his view, great care must be taken to ensure potential Peregrine Falcon nesting areas are not disturbed. The same concern should also apply to the Gyrfalcon and Golden Eagle.

Linegar concluded that the most effective and practical mitigation is to avoid important breeding habitat rather than known active nests. Habitat avoidance ensures all nests are undisturbed and areas are available for new nest sites, recruitment, re-establishment and migration. This method avoids the impossible task of conducting one or more intensive surveys annually to find all raptor nests. It also takes into account the possibility that nesting populations within the study area may have already experienced substantial displacement.

Moving finally to caribou, we have Harrington and Veitch's work on the Red Wine caribou as the only controlled experiment on the impacts of aviation on free-ranging wildlife (Harrington and Veitch, 1992, 1990). Using satellite-tracked radio collars, Harrington and Veitch (1990) studied responses of the George River and Red Wine caribou herds to overflights in Labrador. Five 'control' caribou were compared with five 'target' caribou, to which jet activity was directed. The authors videotaped the behavioral responses of these caribou to the pre-planned overflights. The moment of overpass, elevation and distance of the jet to the animals, type and air force of jet, and other pertinent data were recorded for each overflight:

"When a jet neared the rendezvous point, radio contact was established with the forward air controller, who guided the pilot to the caribou. Pilots were directed to fly directly over the caribou at normal operational speed (775-825 kph.) and at minimum elevation (30 m. AGL). We conducted this 'worst case' approach because we felt we could not obtain a large enough sample size to reliably study the effects of both varied elevation and distance from flight track." The authors went on to conclude that their data "indicate that low-level jet activity, at present levels and types, does not appear to have caused caribou to abandon their home ranges and move elsewhere" (1990:115). While the level of exposure did not greatly affect activity levels of the caribou (about 6-11 seconds of running when overflown), calf survival was lower in the target group. According to Harrington and Veitch, calf survival was "negatively correlated with exposure to low-level flying, which indicates that current levels of training activity may have reached a level where negative impacts on calf survival will become noticeable. Together, the impacts of predators and disturbance from low-level training activity may be preventing the recovery of the Red Wine Mountain population, despite over 15 years of protection from human hunting. The most conservative conclusion from the results presented here is that calf survival is affected by frequency of calving" (1992:217).

It should be perfectly clear then that while there is no conclusive evidence of negative impact on wildlife, there is enough circumstantial evidence to warrant the development and implementation of a thorough avoidance programme. Unfortunately such a programme seems impossible to achieve because Allied air forces cannot live with even the limited restrictions currently in place. And, to accommodate their complaints and veiled threats to abandon Goose Bay if restrictions are not lifted, DND has asked its consultants and the federal and provincial wildlife services to find ways to revise the avoidance criteria so that the restrictions will not seriously interfere with flight training.

The current paradoxical situation faced by DND of attempting to implement avoidance criteria while allowing the continuation of military flight training could well present the Department with serious trouble when it appears before the Environmental Assessment Panel in an effort to defend the environmental soundness of the flight training. The Department is required by the Panel to demonstrate that its avoidance programme will work. But it is increasingly clear that the programme cannot work without driving Allied air forces out of Goose Bay. Something has to give somewhere, either the avoidance of wildlife and people, or the flight training. The available evidence shows that it is avoidance that is suffering which makes the need to invest heavily in scientific experiments concerning the impacts of the training all that more important. Unfortunately, DND has placed all its eggs in the avoidance basket, and has not followed the advice of the Canadian Wildlife Service and other agencies to conduct meaningful research to determine once and for all the nature of aviation impacts on the wildlife of Labrador and eastern Quebec.

(references are available from the author at P.O. Box 1441, Stn.C., St.John's, NFLD, Canada, A1C 5N8)

The Innu, the Environmental Impact Statement and its Relevance to The Netherlands

by drs Roel During

Introduction
For already five years Dutch F-16 jets have been flying above Innu territory. During these years it is yet unclear what harm is done to the indigenous people and their environment. In the discussions on this subject many references are made to the Environmental Impact Statement (EIS). This contribution will provide insight into the current status of this EIS and will outline its function in the decision-making process, both in Canada and The Netherlands, on the admissibility of military low-level flying above Innu territory.

What is an Environmental Impact Statement?
Political decisions made in 1973 and 1977 determined that whenever a Canadian federal government institution is involved in a large-scale activity with major impacts on the physical environment, this activity must be subject to the 'Federal Environmental Assessment and Review Process (FEARP)'. The first step in this process is a screening of possible environmental effects. From the thousands of federal projects, each year there are about ten which reveal an extreme hazardous potential to the environment, leaving no immediate prospects at hand for clear, simple mitigative measures. The federal institution is therefore obliged to do a comprehensive study on these potential effects in such occasions. This meets a twofold goal: (1) to make the environmental risks of the project explicit to such an extent that these can be soundly balanced against other aspects in the decision-making process, and (2) to try, by means of specific research, to attempt to mitigate the anticipated negative environmental effects. The entire procedure of preparing the Environmental Impact Statement is under the review of an independent Environmental Assessment Panel (EAP). This panel issues guidelines, which the EIS must comply with, and it assays the final EIS on the basis of these criteria. The panel also organizes a 'Public Review', in which experts and interest groups can present their views.

An EIS for Goose Bay
A military air base was built in 1941 at Goose Bay, as a result of an agreement between the British, Canadian and American governments. Goose Bay is located in Labrador, Canada. This base became significant in the Second World War because the airport was an important refuelling station on the way from North-American bases to the conflict in Europe. During the Cold War as well, Goose Bay became a very strategic location for the United States in the north. During that time long-distance bombers were stationed at Goose Bay which resulted in the American construction of a large base (28 km2). The American base, however, closed when it became technically feasible to refuel airplanes in mid-flight. Public opinion of military expansion did little for the expansion of the Goose Bay base. Some military activities, however, were maintained for the sake of exercises in Europe. In the early 1980s, the military use of the airport grew again. Military low-level flight exercises became the new activity which stemmed directly from the modernization of air armaments and the matching radar technology. These exercises were held above the surrounding area, a vast, thinly populated taiga landscape, inhabited by a traditional hunter and gatherer society: the Innu people. Beginning in 1986, bilateral agreements between NATO allies, including The Netherlands, and the Canadian government, resulted in such a rapid and intensified use of the Goose Bay airport and surrounding areas, that the sheer quantity of flights warranted the project be subject to environmental review. The urgency for the environmental review was further enhanced due to the fact that the Canadian Ministry of Defense had hopes of planning an extensive NATO Training Center for Tactical Air Combat Training established at Goose Bay. The situation by January 1987 warranted that the newly installed EAP issue guidelines for an Environmental Impact Study. After long delay, the first draft of the EIS appeared in September 1989. To date, no final EIS has been determined and in fact the international low-level exercises continue to expand and are perpetuated, despite (ignored) recommendations of the EAP to freeze the number of exercises.

What is in the EIS?
The Environmental Impact Statement is published in different parts. There is the basic report complimented by a shorter summary, and six technical background reports. A first impression of the contents of the reports can be obtained from Appendix 1. The way in which the main report is divided provides insight into the philosophy of the EIS process. Firstly, the report describes the military low-level flight plans including the proposed routes and areas of exercise. Secondly, there is a full detailing of the natural and social environment. The negative effects are discussed roughly, without reference yet to possible mitigative measures. In addition, a comprehensive plan is presented. This plan serves as the reference from which it can be determined whether negative effects might be prevented or not. The effects which cannot be prevented must be weighed against the benefits of the plan. Defining 'the environment' is problematic in that the inventory of what may be considered 'the environment' may require difficult choices. In order to draw up an inventory of the natural environment, the researchers have used the so-called VEC's (Valued Ecosystem Components). For example, in this EIS, such VEC's may be wildlife in the Goose Bay area. VEC's are chosen on the criteria of their appearance, role in the public interest, economic significance or on the basis of expert opinions. The negative effects on the ecosystem are greatly oversimplified by including or excluding criteria. What results is actually a reduction of those disturbed negatively by low-level flying to a group of 23 animal species and species groups. This implies that some species are more affected than others and that this occurs in isolation - somehow denying obvious interlocking dependencies of the natural world. More attention is given to the social environment in the report. The history of colonization, indigenous land rights and population data are reviewed. Some attention is devoted to the refusal of the Innu organizations 'Conseil Attikamek-Montagnais' and 'Naskapi Montagnais Innu Association' to cooperate. The remainder of the description is divided between the environment in Central Labrador and that of the peripheral areas. In the case of Central Labrador, the consequences on the economic interests of the Happy Valley-Goose Bay community are mentioned. This is a service-economy structured around the base and its activities. The report proceeds with some remarks on schools, universities, hospitals and the inevitable plea (and complaining) for the need to keep those provisions 'up to the mark'. The majority of peripheral communities are somewhat smaller with less than 500 inhabitants. Their economy is based on the harvesting of natural resources, local trade and wage-work. At the local settlement level, fishery and fur trade are important. The EIS concentrates mainly on this use of the land and on the social context of those rural settlement communities. One of the findings of the EIS is a great concern amongst all inhabitants about the low-level flying problem. The reference to the natural environmental effects is dominated by great detail to the caribous, in contrast to other wildlife VEC's. The report further includes the different forms of environmental pollution resulting from low-level flying activities. However, it is 'standard phrasing' in a poorly executed EIS, that on account of background pollution, the negative effects of low-level flying cannot be definitely determined. The description of the effects on the social environment is completely separate of the description of the effects on the natural environment. It is particularly striking to note the section on the 'use of natural resources'. Here, the caribou are regarded as passive objects of hunting, whose activities bear no relationship with flying activities. This is in direct contradiction to the information in another chapter. In a proceeding chapter this appears to be incorrect. Negative health effects are not anticipated, according to the EIS. At worst this may be in the form of a little stress. Especially this part of the report seems to be intended to put salve on the (played down) wounds: the project offers plenty of jobs to the indigenous populations. The mitigative measures are summed up shortly and stem from the principle of 'avoidance', the avoiding of contact (that is, between Innu and jets). Nevertheless, according to the EIS, these measures prove to be very effective. It is speculated that almost all negative effects fail to materialize. And those which do, represent but a handful of the 'minor effects'.

The Opinion of Technical Experts
On request of the EAP, eighteen technical experts have detected (and elaborated on) the main shortcomings in the EIS. To give a complete account of the scientific shortcomings would require a thick book, but it is possible to mention briefly those cases which are in the foreground. In the EIS, no overview is presented of the disputed collective and individual rights of the indigenous people. Moreover, no evaluation is made of the consequences of the project for the negotiations with the indigenous populations. Despite the fact that scientific knowledge provides ample data on this, the Innu economy is not quantified in the report. Rather, the EIS bluntly states that a choice is made to not use the available socio-economic data. And also the secondary sources (information on the Innu associations CAM and NMIA) are not taken into consideration. The predictions of the negative effects do not account for extraordinary circumstances, such as the conditions that occur during flights at night, or during severe winters. The treatment of the effects on the caribou is insufficient. The research is confined to a study of specific existing literature, no field analysis is carried out. Many of the sources used are unscientific because they are unverifiable. The conclusions drawn from the fluctuations in the numbers of the different caribou herds are unscientific and tend to contradict each other. One specialist makes mention of the possibility that wolves avoid the low-level flying routes, which causes the calf mortality rates of one of the caribou herds to decline. The caribous of this herd (the George River herd) display growth disturbances, presumably due to the high cadmium concentrations in the kidneys. Thus is the noise stress overshadowed and insufficiently studied, resulting in the conclusions down-playing the significance of negative effects. This lacks any basis in fact. Also the chance that toxic matter, released under the low-level flying routes, accumulates (via the food chain) in caribou bodies, is not taken into consideration. According to one expert, the potential for the occurrence of such effects is very real. Through the accounts of the experts, many shortcomings of natures come to the forefront. The chances of reducing the number of collisions with migratory fowl are insufficiently elaborated in the EIS. No sound levels have been measured. There are even archaeological mistakes in the EIS. One expert presented a list of as many as 32 shortcomings. Most experts find the number above 20. There is agreement in academic circles that the EIS lacks coherence and is smothered with unscientific data 'supporting' vague texts.

Commentary from The Netherlands
From The Netherlands, the 'Innu Group' within the Foundation Working Group for Indigenous Peoples (WIP) commented on the EIS report. For this, the summary, the main report and the technical documents were studied. The WIP was motivated to give a thorough critical study for two reasons: the timing of the commencement of Dutch F-16 involvement following soon after the direct advice of the Canadian EAP to limit the amount of flights and the political responsibility of The Netherlands to social justice and human rights. Comments from The Netherlands on the quality of the EIS are partly based on direct experiences with the low-level flying problem. The Dutch contributor's expertise is in the field of research in the Waddenzee area, and in the ability to determine the extent to which victims suffer from low-level flying. Dutch expertise lies also in the realization of complaints into a concrete system of accumulated, coherent data. The following is an anthology of the Dutch critique.

Effects on Nature and Environment
To provide comprehensive comments on the effects of low-level flying on nature and the environment, requires careful attention - especially when removed from that situation. As indicated earlier, the description of the effects on nature is done through de so-called VEC's. The selection of those VEC's is highly disputable and unscientific. An obvious criterium such as 'species sensitivity' is not even used in the selection procedure. Further, the criteria that were chosen, were applied inconsistently. In the case of some VEC's, no effects can be given because they do not even appear in the studied area. This is a sad example of the inadequate selection procedure. Pilots prefer to fly in river valleys. However no mention is made of this and there is therefore no evaluations made for repercussions in these areas. The effects on nature are only dealt with in terms of entire populations. The experiences of nomadic observers are inappropriate, since they study mostly the reactions of individuals. In this way, the effects would seem to disappear when they are balanced with the average of the total population. Severe negative effects on moose and caribou are played down as being merely 'local' or as "only relating to an animal species that is hardly found in the area". In this way, serious effects are classified as being 'minor'. It would have been more objective if the effects were indicated according to type of eco-district.

Effects on Health
In the EIS, this subject is addressed in a very tendentious manner. On many occasions were hinderance is mentioned, the following addition is made: "The number of people has to be taken into consideration too." This disturbing sentence is truly unpalatable; it suggests that not too much attention should be given to the single person who experiences hinderance, and that the attention should be rather focused on the positive effects of low-level flying. Naturally, an array of complaints have been filed on low-level flying but no information whatsoever is given about this in the report. Mentioned effects are poorly described. No fieldwork has been done. No research is done into the health situation in the low-level flying area. The unwarranted assumption is made that all inhabitants are as healthy as can be.

Effects on the Economy
The Innu economy is given little attention in the report. There is no quantification. In the reaction by the WIP, however, even if such a quantification would be made, it ought not to be on the basis of European/Western standards.

Largest Fallacies
The proposed mitigative measures to offset the effects of low-level flying are so meaningless, that nobody seriously can believe in their implementation. But the biggest objection has to be made against the summary. This summary is so tendentious and selective in its presentation of the facts, that one cannot come to an independent judgement. Because most people only read the summary, every effort ought to be made to enhance the quality of this summary.

Commentary from Interest Groups in Canada
In anticipation of the completion of the EIS, the Funding Administration Committee has provided funds for 15 interest groups to become involved in the environmental review process. These groups are invited to comment on the EIS, and to put their views and positions in writing as preparation for the public hearings. The funded organizations are seven city councils, the Mokami Project Group (Goose Bay), the Labrador Inuit Association (LIA), the Mokami Status of Women Council, a concerned citizens' group from Wabush, the Makivik Corporation, the Labrador Inuit Health Commission, the Native People's Support Group of Newfoundland and Labrador and the Naskapi Montagnais Innu Association (NMIA). The following is the specific contribution of NMIA as articulated by Peter Armitage, anthropologist at the University of St. Johns in Newfoundland. Peter Armitage has asked 25 technical experts to study the EIS. For this, the best experts within and outside of Canada were approached. Armitage came to the alarming conclusion that not even a single part of the EIS meets the minimum demands of the guidelines that were set by the EAP. The three most serious shortcomings are in the field of the description of:

- the effects of jets exceeding the sound barrier creating a 'sonic boom', - the effects of low-level flying on the Innu, - the effects of low-level flying on animal life.

By failing to recognize or to inform themselves on the traditions, history and survival of the Innu, the Canadian Ministry of Defense belittles the culture and ignores the land rights of the Innu group. No effort was made to test what the Ministry itself holds to be the most important measure, the avoidance measure. The NMIA however has little expectations for this avoidance measure to actually relieve the situation. The jets fly mostly in the valleys, exactly the area where the Innu hunting is concentrated. Moreover, right in the middle of the hunting area, approximately a thousand square miles from their territory are arranged by the military into a bombing practice area. Jets continuously fly back and forth in this area very frequently. More than 60 strategic targets are placed in the hunting area and the low-level flying exercises will concentrate on these. It would seem as though NATO-pilots lack discipline as a small percentage of them continue to make illicit over-flights, as the experience so far indicates. This all is more than enough reason to be highly skeptical about the avoidance principle advocated by Canada's Defense Ministry. In his Compendium of Critiques, Peter Armitage is able to compile the enormous stack of shortcomings and criticisms to a surveyable, 76 'major' problems within the research.

The Guidelines of the EAP put to the Test
After the response period was closed on February 12, 1990, the EAP produced its own list of 38 shortcomings, partly relying on the reactions discussed before from Canadian and Dutch contributions. These flaws must be corrected if the EIS is to fulfill its legal function in future procedures. During the response period some 120 comments in writing were filed.

The Quality of the EIS Conclusion
The EIS, although having mountains of paper on the subject, has yet to finish the conclusions. Methodologically speaking, a lot of criticism can be directed to the depth of the analysis as it is not very profound. For instance, this methodology does not lend itself to measuring the effects of night flying. The report fails in those instances where effects are admitted. These effects are not taken seriously with any notable response and no international literature is cited. On many occasions, effects are down-played. These small mistakes are hard to detect in a report that weighs 5 pounds. The mitigative measures that are mentioned (in the chapter 'mitigation') have hardly been elaborated. Conclusions on measures to reduce negative effects of low-level flying are vague and flimsy. One can assume that these will never be put into practice. But the biggest objection ought to be made against the fact that the summary does not leave any space for independent judgment. From beginning to end, the summary is tendentious. Perhaps the most discriminating aspect of the report's failures is that the four indigenous peoples directly involved must read the bulk of the report in English, as only the summary is in their own language. In the report, the effects of low-level flying on the Innu are not addressed at all. The EAP has to satisfy itself with the report of Peter Armitage. On request of the Innu (funded in this by the EAP), Armitage prepared his own evaluation of the effects.

What is the State of Affairs at the Moment?
Because of the poor quality of the EIS, the EAP had no choice but to return the report, with the list of 38 shortcomings, to the Ministry of Defense. At this moment an effort is being made to correct these shortcomings. Effectively, there is still no approved EIS! What is available is an incomplete and illegitimate product, which has been considered by the EAP to be unfit as a basis for decision-making. More than six years have passed between the start of the exercises and the appointment of the EAP. The now defunct plans for a NATO base excelerated the FEARP procedure. In order to be able to sign the contracts for the establishment of a NATO base, the Minister of Defense had to have at his disposal, a completed EIS procedure. In every letter from the Ministry of Defense, a call was made to expedite things. After the plans for the NATO base were annulled, the 'silence' returned to the department. The low-level flying by the British, the Germans and the Dutch, not to mention Canada, continues. These flights have even accelerated on account of the negative environmental effects of low-level flying in their own countries. All of this without a completed EIS.

Appendix 1 Table of Contents EIS

Appendix 2 The course of the EIS Process

04-22-87 EAP issues guidelines.
05-24-87 EAP publishes the answer of DND on the interim recommendations regarding freezing the number of flights and flight heights.
06-25-87 EAP reacts.
08-27-87 Reaction DND is published, EAP has received information on weapon training schemes.
01-20-89 EAP publishes a list of experts hired for bringing in knowledge.
03-06-89 EAP answers DND about participation problems Innu: EAP respects their reluctance.
07-14-89 EAP furious about leaking parts of EIS, they will have to put those parts at the disposal of the most concerned.
07-24-89 EAP makes concern known to the minister of Defense regarding following the EIS procedures.
08-22-89 EAP announces that the EIS may be ready for release the next month. EAP provides letter DND Goose Bay in which regret about premature disclosure of some sections of the draft EIS is expressed.
09-08-89 Planned date of publication of draft EIS.
09-15-89 EAP gives survey of the further procedure after publication of the EIS in a step by step plan.
09-27-89 EAP announces delay of EIS due to translation problems. DND proposes to deliver the translation of the summary in two indigenous languages two weeks later. The main report is not available at all in any indigenous language. The EAP rejects this proposal.
10-16-89 EAP compiles a survey of subsidized interest groups (very interesting for Dutch decision-making).
10-24-89 EAP accepts draft EIS, but lets the legal participation period of 90 days start only when translations are available, however, no later than two weeks after receiving the EIS.
10-31-89 EAP receives the draft EIS.
11-14-89 EAP starts participation period, which is closed on February 12, 1990. There is no summary in the Naskapi language.
12-15-89 EAP publishes report of the technical experts.
04-04-90 The EAP concludes that the EIS is inadequate in many respects. The panel expresses again her concern over the increase in the amount of flights. She gives recommendations about this and requests monitoring of on-going activities. Reaction of DND: contracts with NATO partners do not have limitations.
05-23-90 EAP gives deficiency statement, among other things based on more than a hundred written reactions.
01-09-92 EAP publishes an adjusted statement as a result of adjustments in the total project (cancellation of plans for extending NATO Training Center).

Appendix 3 Mandate of the Environmental Assessment Panel to Department of National Defense

Appendix 4 Chronology of Military Flight Training Activities over Innu Territory

Appendix 5 Quotes in the Press of Dutch Military Officers

"Over there it is just so inhospitable, you can hardly imagine it. We have at our disposal two exercise areas, of each 62,500 square kilometres. There is completely nothing out there. No village, no road - literally nothing. It's deadly creepy there. You never see anybody, not even a caribou. In all the times that I have flown there, I only one time saw a moose. And that was really the only thing. (...) The claims of the Innu have never been recognized. That is because they settled in the area as late as the beginning of this century. The whites were there earlier than that."

"We've reached the limit where flying safety will be in danger if we go on in this way. A lot of restrictions make the whole area smaller - you are concentrated into a smaller area and the smaller you make it, the bigger the risk is. Of course we have to take care of our wildlife and environment, but we have our concerns. (...) We have co-operated in protecting the wildlife and environment, but now we want flexible boundaries. (...) Everybody has to think about all the operations in Goose Bay and the motive for the economic stabilization here in this environment. The Allies are the fuel for this engine - it is up to the politicians to make up their minds what they want. (...) The biggest threat for the animals are people themselves and not our aircraft."

"To the extent the number of people that do biological studies increases, the number of restrictions increases. Thus, more and more of those rotten dots appear on the map which we have to by-pass. Just a little time and it will be really difficult to follow the whole training program."

"Look, all those red circles and all those lined planes are restricted areas. We only fly high across those areas. And why? Because there are Indian or Inuit camps there, because one single Indian or tourist has announced that he will go fishing there, or because breeding birds have been seen. When we do fly over a camp, it is there own fault: they should have reported where they were."

"The Innu Indians are a degenerated, indolent people. Sure, a sad story. Not one Innu Indian is still nomadic. They have made an alliance with the pacifist movement. That was real smart. Because it gives a lot of publicity. But that is over now. Recently I said to those Innu: Go and set out again for the world. Just tell me through your radio where you are and we'll just avoid you. Is there is famine, give us a signal and we 'll pick you up. (...) I respect the Innu culture, but these Innu are degenerated. They have lost, the peace movement has lost and now they stand in line for compensation. If they had only done it earlier, then it would have been their turn already. It is the fault of the media. They write that there are miscarriages among the caribou because of low-level flying. Nonsense, bullshit man. It's rather the opposite. There are hundred thousand too many of those caribous. Properly speaking, a hundred thousand more ought to be shot from a helicopter to restore the natural balance. Not one argument of the Innu makes sense. It is pure degeneration which has nothing to do with low-level flying."

Appendix 6 Statements of the Dutch government during Parliamentary sessions on the agreement between Canada and The Netherlands on low-level flying

Minister of Defense Van Eekelen, Second Chamber of Parliament, March 3, 1988:

"What is at stake is an area that is uninhabited. In the far surroundings there live 800 Indians. They live in houses. They hunt for some months per year, especially in the wintertime when the animals have a nice fur. There is indeed, as representative Vos has remarked, an overlap period in which there is both hunting and flying. It is particularly in this overlap period that special measures are necessary. In the course of the summer there is no hunting in the interior. Then the climatologic circumstances are such, particularly because of the presence of enormous quantities of mosquitos, the famous black fly, that few people can stand it to remain there for long. Everywhere in that area the Indians move to the coastline and leave the land area. That is one of the reasons that they have no aspiration in that period to go to the area above which we want to fly. In the overlap period there is the arrangement for hunters and pilots to report when they go into certain areas. When they are taken to such an area by Canadian helicopters, there is no low-level flying above that area. No reports have come to me that the system does not work. Naturally I advocate that the promises made by both The Netherlands and Canada are kept as much as possible. If ever complaints arise, we will be happy to see if we can do something about the flying plans, because that is really the only thing that we can change ourselves. The main point is the question why the Indians are against a formalising the agreement and, consequently, the treaty. The environmental aspects are not so much at stake, because they have already stated that they approve of military activities as such. It is a problem that they have with the Canadian government about their claims to land. I don't want to minimize or erase this dispute, but formally this is a matter of the Canadian government. As a matter of fact, the Canadian government is dealing with this issue and there are states in Canada, where there is already the beginning of an agreement. But for The Netherlands it remains undisputed that we cannot interfere in this. In international law we have to deal with the government in Ottawa, which is, for that matter, party to the Human Rights treaty, about which Ms. Beckers spoke, and the government of Canada has the duty to respect this. Canada signed this treaty and Canada guards it. We will respect all Canadian laws, the outcome of the Environmental Impact Statement and the resulting conclusions of the Canadian government. (...) We need the low-level flying in any case for the training of our pilots. It will have to take place somewhere. (...) Ms. Beckers asked why the government hides itself behind the Canadian government, while she accepts co-responsibility for the environment. I don't see a contradiction here. We are prepared to contribute to the environmental study. On forehand we have made it known that we agree with modifications which, as a result of the environmental studies, are deemed necessary by the Canadian authorities in the interest of the environment. This is a extremely positive stance of the Dutch government (...)."

"Concerning the notices that the Agreement would not be in accordance with the International Covenant on Civil and Political Rights the following is remarked. In the Agreement between The Netherlands and Canada is recorded that Canada gives the Dutch government permission to do low-level flying exercises. Agreed is that the Dutch military forces will observe the Canadian legislation that is applied to the Canadian military forces. Both The Netherlands and Canada are party to the International Covenant on Economic, Social and Cultural Rights and the Covenant on Civil and Political Rights. The Dutch government may and must assume that the Canadian legislation meets its obligations to international law. Considering the permission granted by Canada, the undersigned are of the opinion that the Agreement cannot infringe on Canadian law, of which both Covenants at issue are part. The government fails to understand how the signing of the Agreement before a decision is made in the negotiations on the autonomy of the area would at forehand limit the indigenous rights, as the members of the D66 party and the PSP party state. For when the Canadian government makes a decision with respect to low-level flying, the Royal Netherlands Air Force will respect those consequences. Besides, it is clearly stated that exclusively the claims to the land are at stake and that the sovereignty of the Canadian government in the air is never questioned, neither by the Innu Indians. Based on what is stated above, the Dutch government likewise didn't see reason to respond to the complaint at the UN Human Rights Commission in the beginning of March 1988. With concern to the number of Innu Indians that the member of the PSP party talked about, the governments wants to state in all clearness that approximately 800 Indians live in the far surroundings of Goose Bay. Interest groups do indeed state that there are about 10,000 Indians in the area, but then reference is made to the area that the Indians call of old 'Nitassinan'. This area encompasses large parts of Quebec where there are completely no low-level flying exercises. It also encompasses large parts of Labrador. A relatively small part of these is designated as low-level flying area. Both low-level flying areas are uninhabited, but are used occasionally by approximately 260 of the 800 Indians as hunting ground. The low-level flying exercises bring along airplane noise to these hunters. To them, that is a nuisance. But we like to also firmly state that the Innu Indians do not object so much against the military training. The arrival of the Royal Netherlands Air Force has had positive effects also. The local inhabitants of Goose Bay, the majority of which is not comprised of Innu, is applauding the arrival of the Royal Netherlands Air Force, amongst other reasons because of the increased employment opportunities. To be able to make an objective judgement, it seems appropriate to the government to pay attention not only to the negative responses but also to the positive ones, as the spokesperson of the VVD party did in the Second Chamber. (...) The members of the D66 party and the member of the PSP party asked why the government didn't wait for the Environmental Impact Statement before concluding the Agreement. In the note as a result of the report from the Commission for Defense of the Second Chamber (...) the government has indicated that an unacceptable repercussion on the operational deployment capacity of the Royal Netherlands Air Force, which would arise if it could no longer fly at low level, and this must be prevented. For that reason, it was no longer opportune to delay the conclusion of the Agreement with the Canadian government. Because of operational reasons, it was not considered possible to wait for the results of the Environmental Assessment Review Process. Much consideration was given to the fact, that in the Agreement the promise would be made to comply with any consequences Canada would conclude as a result of the Environmental Assessment Review Process. According to the latest information available to the government, this Statement is to be expected some time this year."

"In the whole area of Goose Bay live only 800 Innu Indians. I hope Mr. Vogt [MP] can agree with me calling them, as yet, "Indians". The rest of the population of Goose Bay consists of, what one might call, non-indigenous Canadians. In total it is about 3,000 people. The other population of Labrador consists of about 10,000 Inuit Indians, a people who live exclusively in settlements along the coast. Inuit are not hunters, but fishermen, and they live outside the low-level flying areas in the interior. Labrador has a surface of about one and a half the size of West Germany. This gives you an idea of how large the area is. In the interior there are a few villages of about 3,000 to 4,000 inhabitants. Outside of these villages there is no population. The total population of Labrador is about 31,000 people. I repeat that there is no population living in the low-level flying areas. The Innu say they are bothered by low-level flying. The Innu live in a small settlement near Goose Bay, at the end of the only hardened road which is located - I repeat - outside of the low-level flying area. At the start of the hunting season, the Canadian government transports a few groups of hunters on their request by helicopter to the hunting area. Every two or three weeks, the Innu Indians are supplied, or are moved to another place, at the expense of the government. Upon request, the Innu Indians are brought back again to Goose Bay. With this I want to substantiate the fact that the Canadian government is making great efforts to have the Innu Indians participate as much as possible in the traditional way of life. At their own request they are taken by helicopter from their dwelling-place to the hunting area and back. And with this I also like to point out that the places where the hunters are to be found, are naturally known to the Canadian government.On air maps these places are marked. During the flight exercises these places are avoided. Airplanes stay outside a radius of about 4 kilometres. The apparatus on board of the F-16 jets is so advanced and accurate, that it enables the pilots to avoid all those places. The same procedure is followed for the avoidance of caribou herds. The number of caribous has risen quite substantially over the past few years. Each day, on basis of the latest data, the position of these herds is marked on the air maps that the F16 pilots use, so that these herds can be avoided.(...) About 30 percent of our total need of F5 and F16 low-level flight training is transferred to Canada [From West Germany]. This percentage might rise, with the rate that the conversion of F5s to F16s proceeds. We foresee that towards the end of the conversion period, in 1992, about 40 percent may be transferred from West Germany. It is quite clear that this will be extremely pleasant to our eastern neighbours! Ms. Smeets and Ms. Tiesinga [MP's] have asked to what extent is it possible to verify the avoidance of the hunting Innu. I repeat what I have said, namely that the accuracy of the navigation equipment of the F16s is so advanced that the possibility of over-flying fish or hunting camps has to be practically excluded. (...) What is this matter all about? The Dutch government has a problem. In the defense concept, that is used by the air force, low-level flying is an absolute necessity. So the pilots of the F16s have to be trained in doing that. The members [of parliament] know how much the Federal Republic of Germany objects against low-level flying above that country. We all know what the concerns of our eastern neighbours are and to what extent they are annoyed and hindered by these exercises."

"We are negotiating with the Canadian government [about expansion of the low-level flight training program], which is being studied for its environmental impact. It is up to her to draw this into the negotiations. For that matter: the negotiations are currently being held within an existing frame work agreement. The Canadian EIS will play a role at the moment when the agreement with The Netherlands and other users of Goose Bay will have to be extended. At this moment, all we are doing there fits completely within the Canadian legislation, as otherwise, the Canadian government would not even cooperate."

"You speak about allied consultations and 'owning responsibility'. I have given the example of the responsibility which we take with the export of chemical waste. Likewise, I think we ought to know in this connection, what the effects are on nature and environment in Canada. Will the Chamber be able to peruse the Canadian EIS, so that it can see for itself what The Netherlands is exporting and what the possible effects might be?"

"I think that this is, in the first instance, a responsibility of the Canadian government. It is busy with this and as long as it considers it justifiable to continue such activity, I see no reason why we should not do it ourselves. Besides, based on my own experience, I may add that the population in that area [in Canada] is cheering of joy if we extend the exercises. A very small group questions this activity for whatever reasons! (...) I expected that I would have to walk very carefully with small steps, so I was surprised when I did not need to explain why we were doing exercises there and that the community councils over there only asked for more people and more exercises.(...) I had quite a few meetings in Ottawa as well in which the impression was given that expansion of the exercises would not pose to much of a problem."

Appendix 7 Letter by the Royal Netherlands Air Force to a Concerned Citizen

The Hague, October 20, 1992

Concerns: low-level flying exercises in Canada

Dear Sir,

1. In answer to your request to terminate the participation by the Royal Netherlands Air Force in low-level flying exercises above Canada, which I was asked to handle, I inform you of the following.

2. In contrast to what you assume, there are low-level flying exercises with jet bombers in The Netherlands. For this we have in our country two low-level flying routes. But considering the limitations in the use of these routes, the Royal Netherlands Air Force is conducting, amongst others, a part of the necessary low-level flying training above sparsely populated areas in Canada.

3. In the agreement between Canada and The Netherlands made for that reason, the appointment is made that the Dutch army will respect the laws, regulations and prescriptions that are applied to the Canadian army, amongst others those with regards to the protection of the environment.

4. The Canadian authorities have taken a number of steps to guarantee that low-level flying exercsises over Canada do not interfere with the traditional way of living of the locally resident Innu. In this respect, for example the flying below 600 meters within a radius of 4.5 km above settlements, fish and hunting camps and herds is off-limits. In addition, the Innu have received - gratis - communication equipment to transmit their moves between hunting grounds to a central control room. These data are subsequently incorporated in aircrew's flight plans, thus allowing the hunting camps of the Innu to be avoided.

5. Worth mentioning is the fact that the number of Innu with a so-called 'nomadic configuration', is about 1,000. Moreover, a study done in May 1987 in Labrador on caribou and low-level flying showed that although the air traffic has increased, the number of caribou in the passed 8 years has doubled from 380,000 to 750,000.

6. Finally, I inform you that the Canadian authorities are busy already for some years to test the measures that they have taken on their effectiveness. However, the Environmental Impact Statement (EIS) process has not yet been completed; the EIS will be further studied by the so-called Environmental Assessment Review Panel. For the moment, it is not really possible to foresee when this procedure will be finished. The final recommendation is not to be expected before the middle of 1994. Only after that, it is possible to judge whether low-level flying above Canada is to be continued.

For the Director Operations
Royal Netherlands Air Force,
Head Supporting Operations Division,
J. van Harmelen
Lieutenant-Colonel.